What is the EU Taxonomy?
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Discover the EU Taxonomy: what it is, how it defines sustainable activities, and its impact on businesses and financial markets.
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What is the Ecodesign for Sustainable Products Regulation (ESPR)?
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“ Most of us are probably unaware that the products we purchase every day - from our smartphones to the clothing we buy - can contribute to environmental harm. Issues like environmental degradation, resource depletion, and the release of greenhouse gas emissions are linked to these seemingly harmless items. ”
Over the years, the EU has developed a series of ambitious environmental goals, such as the European Green Deal and its Fit for 55 ambitions. As part of these efforts, it has also set its sights on ensuring that the products entering the EU market are designed with sustainability at their core.
This is where the Ecodesign for Sustainable Products Regulation (ESPR) comes in. Entering into force in July 2024, the ESPR is designed to ensure that products sold in the EU are durable, energy-efficient, repairable, and recyclable.
Unlike its predecessor, the 2009 Ecodesign Directive, which mainly targeted energy efficiency in products like fridges and washing machines, the ESPR expands the scope to almost all product categories, placing a strong emphasis on product circularity. The regulation introduces measures to improve sustainability, including the Digital Product Passport (DPP) and a ban on the destruction of unsold consumer goods.
By introducing these changes, the ESPR aims to reduce the environmental footprint of products at every stage of their lifecycle - right from raw material extraction through to their end-of-life disposal.
In this article, we will explore what the ESPR means for sustainable product design, the key requirements involved, and how it will impact businesses across the EU.
What is the Ecodesign for Sustainable Products Regulation (ESPR)?
The ESPR is a significant advancement from the earlier Ecodesign Directive (2009/125/EC), which only focused on the energy efficiency of a limited number of product groups, such as household appliances.
Note : in 2021, the Ecodesign Directive (2009/125/EC) was responsible for a 10% reduction in energy consumption of regulated products, resulting in energy savings of €120 billion for consumers.
However, the European Commission recognized that products have environmental impacts beyond just energy use, and so they proposed the ESPR as part of its Circular Economy Action Plan, which forms a cornerstone of the European Green Deal.
- The ESPR covers a wider variety of product categories and introduces sustainability measures that go beyond energy efficiency.
- It introduces stricter rules on durability, repairability, and recyclability, and also addresses issues such as the presence of harmful substances and product lifecycle management.
- The ESPR shifts the focus from just reducing energy consumption to building a circular economy model. This means that products placed on the EU market need to be designed with their entire lifecycle in mind: promoting their reuse, the ability to upgrade, and the recycling of the item.
A key aspect of the ESPR, is the the Digital Product Passport (DPP), which provides detailed, accessible information on a product’s sustainability performance, materials, and end-of-life instructions. This will help businesses, consumers, and authorities track a product’s environmental impact, and will ensure more accountability throughout the supply chain.
“ The Ecodesign for Sustainable Products Regulation (ESPR) is a significant step forward from the earlier Ecodesign Directive (2009/125/EC), which mainly focused on the energy efficiency of certain product groups, such as household appliances. ”
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Key objectives of the ESPR
The ESPR is an ambitious piece of EU policy, aimed at transforming how products are designed, used, and disposed of within the European market. Its core objectives go beyond just energy efficiency to address a wide range of environmental concerns, including:
Promoting circularity and resource efficiency
One of the most significant shifts introduced by the ESPR is its focus on enhancing the circularity of products. This means designing products to be:
⏱️
Durable: Products must last longer, reducing the need for frequent replacements.
🛠️
Reparable: The ESPR focuses on the ease of repair to extend product lifespans.
👍
Reusable and upgradeable: Products should be designed in a way that makes them easy to upgrade, enabling consumers to add new features without replacing the entire product.
♻️
Recyclable: Ensuring that the materials used can be easily separated and recycled at the end of a product's life.
By focusing on these key aspects, the ESPR hopes to reduce the overall demand for raw materials, which are often tied to harmful environmental impacts like resource extraction, deforestation, and pollution - to name just a few.
Reducing carbon and environmental Footprints
The ESPR also aims to encourage manufacturers to minimise both the carbon footprint and wider environmental impacts of their products.
This includes things like reducing the use of hazardous chemicals, improving resource efficiency, and encouraging the use of recycled materials in products.
Banning the destruction of unsold goods
Another key objective of the ESPR is to combat waste through its ban on the destruction of unsold goods. Many companies - particularly in the fashion industry - have been criticised for destroying unsold inventory, which is incredibly harmful for the environment.
The ESPR introduces rules that will phase out the destruction of unsold products, starting with textiles and footwear, which must either be reused or recycled.
Digital product passport (DPP) for transparency
To improve the transparency and traceability of products, the ESPR introduces the Digital Product Passport (DPP), which will store essential information about a product’s sustainability performance, materials, origin, and recycling options.
The DPP will be accessible electronically and will help both consumers and authorities make informed decisions about product sustainability. It also supports regulatory compliance by making it easier to track the life cycle of products from production to disposal
Aligning with the circular economy action plan
The ESPR is part of the broader Circular Economy Action Plan under the European Green Deal.
By introducing measures that address the environmental impact of products throughout their entire lifecycle, the ESPR supports the EU’s efforts to decouple economic growth from resource use, while encouraging innovation in sustainable product design.
The role of the Digital Product Passport (DPP)
As we've already touched on, one of the main features of the Ecodesign for Sustainable Products Regulation (ESPR) is the introduction of the Digital Product Passport (DPP).
- This new tool is designed to improve transparency, traceability, and sustainability in the supply chain by storing and sharing critical product information in an accessible digital format.
- The DPP is key to ensuring that both consumers and authorities have the information they need to make more sustainable choices and enforce regulatory compliance.
What is the Digital Product Passport?
The Digital Product Passport (DPP) is essentially a digital profile assigned to products, components, or materials, and includes information on their sustainability performance, composition, and lifecycle.
It is designed to be used by stakeholders at all levels of the supply chain - ie. manufacturers, regulators, and consumers - and gives access to important data about a product's environmental impact.
The passport will include details such as:
🧱
Materials used: Information about raw materials and their origins, which helps track whether they are sustainably sourced.
🔍
Sustainability metrics: Data on a product’s carbon footprint, recyclability, and the presence of any harmful materials.
♻️
Repairability and recyclability: Guidance on how the product can be repaired or recycled at the end of its life.
📝
Product lifecycle information: Insights into the expected lifespan of the product and how it can be disassembled or reused.
Note : the DPP aims to create a closed-loop system, where the environmental impact of a product is tracked and minimized from the design stage to its end-of-life management.
How will the DPP work?
The DPP will be linked to products via a scannable QR code.
- Information stored in the passport will be available through a DPP registry, allowing easier verification by customs authorities, market surveillance authorities, etc.
- This will be particularly useful for ensuring compliance with the ESPR across different product categories.
The DPP will include:
🧐
General product information: Accessible to consumers to help them make informed purchasing decisions.
📄
Detailed technical documentation: For manufacturers, recyclers, and repair services, enabling the product to be managed responsibly throughout its lifecycle.
Benefits of the Digital Product Passport
The Digital Product Passport offers a number of advantages, including:
Transparency
The DPP provides clear and accessible information, allowing consumers to understand the environmental and social impact of their purchases.
Enhanced regulatory enforcement
By giving regulators easy access to key product data, the DPP simplifies the enforcement of the ESPR’s rules, helping ensure that only compliant products are sold in the EU.
Support for a circular economy
The DPP’s detailed information on recyclability and repairability will support efforts to keep materials in use for longer, helping to reduce unecessary waste.
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Product-specific and general ecodesign requirements
Another key aspect of the Ecodesign for Sustainable Products Regulation is the framework for establishing ecodesign requirements.
- These requirements help ensure that products sold in the EU meet stricter environmental standards throughout their entire lifecycle.
- The ESPR encompasses a dual approach by setting both product-specific requirements and general sustainability rules that apply across different product categories.
Product-specific ecodesign requirements
The ESPR allows the European Commission to set specific environmental rules for particular product categories through detailed regulations known as “delegated acts”.
- These regulations are based on impact assessments and consultations with key stakeholders to ensure they align with the EU's sustainability goals.
- Priority products include textiles, electronics, and energy-related products.
The performance requirements for these products include elements such as:
🦾
Durability: Ensuring products last longer, reducing the need for frequent replacements.
🛠️
Reparability: Designing products that are easy to repair, either by consumers or professionals.
🔩
Recyclability: Making sure products can be easily dismantled and recycled at the end of their life.
🔋
Energy efficiency: Reducing energy consumption, particularly in high-energy products like household appliances.
In the electronics industry, for example, the ESPR could enforce strict guidelines on making devices like smartphones or laptops easier to disassemble for repair or recycling. This could include requirements for manufacturers to use standardized screws and avoid excessive use of adhesives that make devices difficult to open. Not only would this help to extend the lifespan of devices as consumers would be able to simply replace faulty or aging components but it would also allow recycling facilities to separate valuable materials, such as rare earth metals and plastics, which would improve recycling processes and reduce the environmental impact of discarded electronics.
General ecodesign requirements
In addition to product-specific rules, the ESPR also introduces general sustainability standards that apply to a wide range of product categories.
Examples of general requirements include:
Resource efficiency
Reducing the use of raw materials and encouraging manufacturers to include more recycled content in their products.
Reducing hazardous substances
Limiting or eliminating harmful chemicals that make recycling or reuse difficult.
Information requirements
Ensuring products come with clear instructions on how to repair, recycle, or dispose of them responsibly.
A gradual rollout of requirements
The ecodesign requirements - both product-specific and general - will be implemented gradually. The timeline and product priorities are determined by the Ecodesign Forum and the ESPR Working Plan.
In April 2025, the European Commission adopted the 2025–2030 ESPR and Energy Labelling Working Plan, which identifies which products will be prioritized for new sustainability rules over the next five years.
Priority products include:
- Steel and aluminium
- Textiles
- Furniture
- Tyres
- Mattresses
The plan also introduces horizontal measures, such as a repairability score and improved recyclability requirements for electronics and small household appliances.
Detailed rules for each product group will follow in delegated acts. For some energy-related products, work under the previous Ecodesign Directive will continue, with updates expected by 31 December 2026.
Ban on the destruction of unsold goods
One of the boldest measures introduced by the ESPR is its ban on the destruction of unsold consumer goods.
- This regulation addresses a significant issue in industries - particularly in fashion, electronics, and retail - where unsold inventory is often destroyed to avoid costs related to storage, discounting, or recycling.
- This results in enormous waste, as valuable resources are discarded rather than being reused or recycled.
Focus on the fashion industry
The fashion industry is one of the primary targets of this ban.
Fast fashion brands often face excess inventory that is unsold due to overproduction, trends changing rapidly, or seasonal changes.
Instead of selling items at a discount or donating them, many companies opt to destroy unsold clothing and accessories to maintain their brand’s image or avoid paying to store them.
Under the ESPR, starting in 2026, large companies will no longer be able to destroy unsold textiles and footwear. Instead, they will be required to either recycle, donate, or repurpose these items, reducing unnecessary waste and saving resources.
Expanding to other sectors
Although the initial focus is on textiles and footwear, the ESPR leaves room for expanding the ban to other sectors in the future.
Electronics, for example, is another industry where unsold goods are often destroyed due to rapid product cycles, with newer models replacing older ones before all stock is sold.
With the ESPR in place, companies in these sectors will be required to find sustainable alternatives to destroying unsold items, either through refurbishment, recycling, or donation.
Transparency and accountability
The ESPR also requires companies to be transparent about their disposal of any unsold goods.
Large businesses will have to disclose how many unsold products they get rid of every year, as well as the reasons for discarding them. This information will need to be made public on their website, helping to hold companies accountable for their waste practices and providing consumers with greater transparency.
Medium-sized enterprises will have until 2030 to comply with this ban, giving them more time to adapt to the new rules. Smaller companies, due to their limited resources, are currently exempt from the ban, although they are encouraged to adopt more sustainable practices.
Will the ESPR impact non-EU companies?
“ The ESPR doesn’t just impact products made within the EU, it also affects those imported into the EU market. As one of the world’s largest trading blocs, the EU’s environmental standards have significant global consequences. ”
Under the ESPR, any products sold in the EU - whether manufactured domestically or abroad - must meet the same sustainability and circular economy requirements.
Impact on global trade
The ESPR aligns with international trade rules but raises the bar on what is required for products to enter the EU market.
🟣 For manufacturers outside the EU
✅ This means adapting their products to meet EU sustainability standards, such as ensuring durability, repairability, and recyclability, as well as complying with the new Digital Product Passport (DPP) system.
🔍 The DPP will track the sustainability performance of products and materials, which could make compliance more complex for companies that rely on global supply chains.
🔵 For developing countries
⚠️ Some of them export large quantities of textiles, electronics, and other products to the EU, and these new requirements may pose challenges.
🤝 However, the EU has committed to supporting its trade partners, providing assistance to help align their production processes with the ESPR's standards.
“ The ESPR doesn’t just impact products made in the EU, it also affects those imported into the EU market. As one of the world’s largest trading blocs, the EU’s environmental standards influence practices across the globe. Under the ESPR, any products sold in the EU - whether manufactured domestically or abroad - must meet the same sustainability and circular economy requirements. ”
Challenges and opportunities for companies
The ESPR brings both challenges and opportunities for businesses operating within the EU and those exporting to the EU market.
The regulation raises the bar for product design, sustainability, and transparency, which will mean that companies have to make adjustments to their operations, but it also opens up new opportunities for innovation and market competitiveness.
The main challenges faced by companies include:
| Business Challenge | Description (Why) | Tip to Overcome It |
|---|---|---|
|
Redisign products for durability, reparability, and recyclability
|
New standards require businesses to design products that last longer, are easier to repair, and can be recycled, which requires re-thinking traditional product designs. | Invest in R&D for innovative, modular product designs, and partner with sustainability experts to ensure compliance. |
|
Compliance with the Digital Product Passport (DPP) system
|
The DPP demands tracking and sharing detailed product lifecycle data, which can be technically complex and expensive to implement, especially when supply chains span numerous countries. | Develop or adopt digital tools to track lifecycle information, and work with tech providers to streamline DPP integration. |
|
Managing complex global supply chains
|
Global supply chains often involve many suppliers and regions, making it difficult to ensure that all parts of the chain comply with the ESPR standards. | Enhance communication with suppliers, conduct regular assessments, and adopt lifecycle assessment tools to maintain compliance. |
|
Substance transparency and reducing hazardous materials
|
The ESPR aims to reduce the use of harmful materials in goods and asks companies to audit materials used and find eco-friendly alternatives. | Conduct thorough audits of materials used and actively research or invest in alternative materials to replace harmful ones. |
|
Cost of implementing new technologies and processes
|
Implementing these changes will likely require significant investment in new technologies and processes, which can be particularly challenging for smaller businesses. | Take advantage of available EU and government grants to help reduce costs, and focus on long-term savings through improved resource efficiency. |
- However, the ESPR also provides opportunities for companies willing to adapt. Businesses that embrace sustainable product design can gain a competitive advantage - there's a growing demand for eco-friendly products. As consumer awareness of environmental issues grows, offering sustainable products can enhance brand reputation and attract a sustainability-conscious customer base.
- The ESPR also encourages innovation. Companies that invest in research and development to create more sustainable products will not only reduce their environmental impact but could also lower long-term production costs. By optimising resource use and minimising waste, businesses can improve efficiency and potentially save on material costs.
“ In the long run, the ESPR may help companies future-proof their operations, as stricter environmental regulations become more common worldwide. Adopting ESPR standards now can prepare businesses for similar regulations in other markets. ”
Round up
“ The ESPR marks a major shift in how products are designed, produced, and managed within the EU, pushing for higher sustainability standards across industries. As the regulation continues to roll out over the coming years, it is set to evolve in response to new challenges and innovations in the market. ”
The scope of the ESPR is set to expand in the coming years to include other product categories and industries. While the initial focus is on textiles, electronics, and energy-related products, other sectors like construction materials or food packaging could eventually fall under the regulation.
The ESPR aims to facilitate a wider shift towards a more circular economy. By minimizing waste, reducing the consumption of limited resources, and lowering carbon emissions, we can reduce the environmental footprint of the EU consumer market.
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How Greenly can help your company
The ESPR paves the way for a major shift in how products are designed, manufactured, and sold in the EU. To comply, businesses will need precise, auditable product-level data on environmental performance, from carbon footprint and material use to repairability and recyclability.
That’s where Greenly’s Life Cycle Assessment (LCA) platform comes in.
Greenly's LCA Solution
Greenly’s platform enables product teams to run science-backed, ISO-aligned LCAs and integrate eco-design into every stage of product development. Unlike traditional approaches, which rely heavily on manual consulting, our AI-powered automation makes LCAs easier to deliver and scale across entire product portfolios.
With Greenly, you can:
Scale LCAs efficiently
Bulk-import your bill of materials and autonomously generate LCAs for as many products as you like, with up to 90% of the process automated.
Ensure regulatory compliance
Our methodology aligns with ISO 14040/44 and ISO 14067 and supports EPD, FDES, and PEP reporting — helping you prepare for ESPR requirements and the integration of Digital Product Passports.
Leverage robust data
Access one of the largest emission factor databases available, with 300,000+ impact factors from Ecoinvent, IEA, PEF, Agrobalyse, and more.
Empower your product teams
Our intuitive, no-code platform enables teams to run LCAs, simulate design changes, and model low-carbon material substitutions — without needing to be LCA specialists.
Making LCAs accessible
Traditionally, LCAs have been expensive, time-consuming, and limited to a small number of products. Greenly changes this by making LCA a continuous, data-driven process:
Unlimited scalability
Generate LCAs across your entire product catalogue using your customized reference framework, ensuring consistency at scale.
Real-time insights
Visualize environmental impacts down to the material, component, or process level to identify hotspots and guide eco-design improvements.
Eco-design simulations
Test design changes, compare material options, and model low-carbon substitutions directly within the platform.
Greenly helps you stay ahead of evolving sustainability requirements with our LCA platform and wider Sustainability Suite. We give you the tools to measure, manage, and reduce your environmental impact, while preparing for Digital Product Passports and future reporting obligations.
Get in touch today to learn how Greenly can support your ESPR strategy and help you turn regulatory challenges into opportunities.
Sources
Ecodesign for Sustainable Products Regulation, European Commission, https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en
Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products (recast) (Text with EEA relevance), EUR-Lex, https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32009L0125
Ecodesign for Sustainable Products Regulation (ESPR) – 2024 Overview, Ecochain, https://ecochain.com/blog/espr-2024-overview/
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